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1.6 Technical Approach <br />Sample placement prescribed by Nuclear Regulatory Commission (NRC) Regulatory Guide 4.14 <br />(RG 4.14) was modified in order to ensure the effort put forth in characterization of the project <br />site is adequate and assures an appropriate determination of background parameters including <br />radiation. Modification of the sampling program described in RG 4.14 is appropriate as this <br />guidance was developed to be used in design of an environmental monitoring program for <br />conventional uranium mill and tailings sites and was not specifically intended to address ISR <br />operations. The modified sampling program adequately characterizes radiological and non- <br />radiological aspects of the environment at the site and assists the applicant in the proper <br />placement of operational monitoring sites to ensure standards for protection of human health and <br />the environment will be met during mining operations. The modifications were reviewed with <br />representatives of DRMS, CDPHE and EPA, as appropriate. <br />The SCP consists of the following components: <br />• Groundwater monitoring <br />• Domestic well water monitoring <br />• Surface water monitoring <br />• Air quality monitoring <br />• Surface soil monitoring <br />• Subsurface soil monitoring <br />• Radon flux measurements <br />• Thermo-Luminescent Dosimeter Program <br />• Direct radiation measurements <br />• Vegetation and food product sampling <br />• Animal tissue sampling <br />• Cultural resource inventory <br />• Noise survey <br />in general, sample collection and analyses were performed according to industry accepted, peer <br />reviewed and/or EPA-approved methods. All samples were collected using clean and calibrated <br />instruments and equipment. Glassware and plastic containers were furnished via a certified <br />analytical laboratory, in sealed ice chests with pre-measured preservative chemicals. All non- <br />disposable sampling equipment and implements used were washed with deionized water and/or a <br />critical cleaner such as Alconox between each collection. Technicians donned clean gloves <br />before collecting each sample and all necessary fields and sample information was recorded. <br />Each sample was labeled, sealed, stored at appropriate temperature and was shipped to a certified <br />analytical laboratory with proper `Chain of Custody' documents before holding times expired. <br />April 2009 4 Site Characterization Plan